1. Background: Nigeria covers 356,669 sq miles and has a
population of approximately 135 million. The major languages are
English (official), Yoruba, Igbo, and Hausa. Approximately 60% of
the population is below the poverty line for Nigeria. The current
GDP is 1,500 dollars, and the inflation rate is 8.2%. This high
poverty rate, coupled with the population pressures, induces
large-scale migration.

2. Nigeria has very limited internal controls regarding issuance of
documents, to include passports. The lack of controls and a high
incidence of bribery that permeates every level of society create an
environment where anything and everything is available and for sale.
With enormous hunger for visas as an escape route, documents that
cannot be trusted, and security situations that make travel
difficult, Lagos is without a doubt a high-fraud post.

---------
NIV FRAUD
---------

3. The NIV unit continues to see fraudulent documents submitted to
create the impression of an established travel history. On December
13, two groups of three NIV applicants, supposedly traveling
together for training and sponsored by their employers, applied for
B1 visas. The interviewing officers noted that two of the three
applicants in the first group had fake French Schengen Visas: the
print was incorrect and the holographic foil feature was of very
poor quality. Their passports also had matching fake entry stamps
for France, clearly hand-carved. The second group of three each had
fake UK Schengen visas, printed on identically wrong visa foils and
with hand-carved UK entry stamps.

4. The applicants were interviewed by the FPU and ARSO/I together,
and while some of the applicants contended that the visas were real
and they had in fact traveled to Europe, several of the applicants
confessed that they had paid a man to set them up with documents and
an appointment. They had never met their fellow applicants before
that morning outside the Consulate. One of the applicants said that
he paid 50,000 Naira for the documents, the equivalent of 430
dollars, while the others who confessed said they had paid 300,000
Naira, or 2,500 dollars. These applicants were handed over to the
Nigerian police.

5. R1 religious worker visas continue to be a point of concern. In
the case of large religious groups such as the Catholic Church,
there are established organizations with which we can work to verify
the claims of applicants in Nigeria and the receiving church in the
United States. Smaller churches, such as the evangelical sects,
present more of a problem when it comes to authenticating documents
and membership. The ongoing investigation by DHS into the Redeemed
Christian Church of God (RCCG) in Texas has meant that officers have
been refusing R1 applicants for that organization under 221g pending
the outcome. Since beginning this practice, post has seen applicants
for other petition-based NIVs, mostly H1Bs, who are going to work
for consulting and accounting firms whose clients include the RCCG;
post has refused these applicants under 221g as well.

--------
IV FRAUD
--------

6. The bulk of the FPU's resources are devoted to unearthing fraud
for IV and DV cases. FPU conducts field investigations to verify
the validity of submitted documents and claimed relationships. FPU
investigators have built up a stable of trustworthy contacts in
various regions of the country over the years. These have proven an
invaluable resource, as Nigeria is a country where the public
officials themselves are often implicated in the deception, whether
through ignorance of their own laws or through actual corruption.

7. F-1 unmarried adult children of American citizens continue to be
a source of fraud investigations. Field visits by our investigators
routinely find purportedly unmarried F-1s living with a spouse and
children. Applicants also attempt to thwart our efforts at a field
investigation by providing false contact information, which
unfortunately adds to the duration of the investigation.

8. IR-2 stepchildren also present a challenge. The typical case
involves a parent who travels to the United States on a visitor visa
and then divorces the Nigerian spouse shortly after traveling or in
some cases shortly before departure. The parent finds an American
citizen spouse, whom they marry to adjust status, and then the
American citizen petitions for the children in Nigeria as
stepchildren. FPU utilizes a number of tools to combat this fraud.
CCD searches show whether or not left-behind spouses have been
issued a visa themselves, while Lexis-Nexis allows us to see if the
petitioner and biological parent are listed as living together. An
FPU field investigation shows whether or not the surrounding
community is aware of the divorce, and whether or not the biological
parent in the United States is carrying on a relationship with the
left-behind.

9. In one recent case, the purported stepmother in the United
States filed for a pair of stepchildren. The biological father had
traveled on an NIV a number of years before, divorcing the
biological mother before he left. He had not had any children with
the wife in the United States, but had fathered a child who was born
in the United States with another woman with whom he said he had an
affair. The birth certificate was submitted. According to CCD
records, the biological mother had been refused an NIV a year or so
after the father traveled and had not applied since. The mother of
the baby born in the United States had also applied for NIVs and
received them.

10. A comparison of the photos of these two women showed that they
were in fact one and the same; after being refused an NIV, the
biological mother applied under a false name, traveled to the United
States, and bore a child for a man from whom she was supposedly
divorced. When the children, aged 8 and 10, were shown the two
photos - mother under her own name, and mother under the false name
- they denied recognizing either. However, the older cousin who
brought the children to the interview was called up and, ignorant of
the reason behind the question, promptly identified both photos as
the mother of the applicants. As the relationship between the
petitioner and the biological father was clearly a sham, the
petition was revoked. The information was sent to the FPM at NVC to
aid in the revocation of the biological father's LPR status.

--------
DV FRAUD
--------

11. Educational qualifications continue to be a fraud concern for
the DV. Post has found an established fraud trend wherein
applicants finish secondary school a decade before winning the DV,
and the scores for their West African Examinations Council (WAEC)
exam, usually taken at the end of their final year, are very poor.
Flash forward to the present, when they win the DV lottery and
decide to re-take the exam after some 'private tutoring.' These
scores are very strong, but when the applicant comes for his
interview he knows nothing about the subjects in which he supposedly
excelled just months before. We have had a number of applicants
confess under questioning in the FPU that they had assistance in
completing the exam; in some cases, they were assisted by a fellow
test taker. More alarmingly, in some cases they claim the test
proctor read off the correct answers. In such instances the
documents are good and, were we to verify them, would be found
legitimate, but the applicants have no claim to the scores on them.

12. Lagos also sees a large number of 'clip-ons,' spouses acquired
after entering the DV lottery. Many of these prove to be fraudulent
relationships. While FPU conducts some field visits to determine
the validity of relationships, in many cases a simple split
interview in the FPU offices suffices to verify relationships.

13. In one case, a young man who won the DV clipped on TWO spouses.
When asked about this in his interview, he stated that he met wife
number two, who accompanied him to the interview, approximately
three months before entering the DV, and he said that by the
following January - a month after entering - he and this woman had
'an understanding.' All well and good, except that he married wife
number one and clipped her on in February. He claimed that wife
number one died the following August, and in September he married
wife number two.

14. The interviewing officer sent the case up to FPU for a detailed
split interview, where it became clear that the applicant and wife
number two were not married at all. It appears that wife number one
was to be the 'bankroll,' a person who agrees to pay application
fees and plane fares in exchange for being added to the application,
and when it became clear to him that she was not going to provide
the promised funds, he 'killed her off' on paper and found a new
bankroll. The primary applicant was found 6E for alien smuggling
and wife number two 6C1 for material misrepresentation.
---------
ACS FRAUD
---------

15. Financial scams - known as '419' scams after the section of the
Nigerian penal code relating to financial crime - continue to be a
huge issue for ACS. The ACS Unit receives an average of 20
inquiries daily through e-mail and telephone from American citizens
as well as citizens from other countries who have been defrauded by
Nigerians posing as romantic interests, Americans in distress, or
lawyers trying to disburse a settlement or inheritance. Some of
these American citizens have sent large sums of money to Nigeria.
Unfortunately, all we can do is refer them to the Economic and
Financial Crimes Commission in Nigeria and the Secret Service in the
United States.

16. The U.S. passport continues to be a highly coveted document.
One recurring scenario is the first-time passport applicant who is
in his late teens. The applicant will provide a birth certificate
for a child born in the United States, as well as perhaps an infant
passport, or the passport of the purported mother with the child
endorsed in it. FPU does field investigations to verify the
identity of the applicant as that listed on the birth certificate.

17. Post also sees many applications for Consular Reports of Birth
for the children of recently-naturalized male American citizens. In
order to qualify as an American citizen from birth, a child must be
born after the American citizen has naturalized, and in some of the
applications the timing is very close. In one case, FPU
investigators went to the hospital in question to verify the
hospital documents the mother submitted as evidence of birth for the
baby. The investigators found that the registration number on the
documents was in the hospital's records for another woman; the
hospital records and birth certificate were not legitimately issued.
The parents had attempted to move the child's birth date forward in
order for him to qualify for citizenship.

--------------
ADOPTION FRAUD
--------------

18. Local courts continue to issue suspect adoption orders. In
order to be a valid adoption under Nigerian law, adoptive parents
must fulfill certain requirements, including but not limited to
three months of custody of the child prior to the adoption order, as
well as a personal appearance in court on the day the adoption is
finalized. These requirements are frequently ignored by Nigerian
courts, resulting in procedurally-invalid adoptions.

19. Starting in 2006, all adoptions coming through ConGen Lagos go
a mandatory field investigation to ensure that the laws of Nigeria
and the United States were followed during the adoption process.
Our investigators conduct a home visit to see if the child is living
with the appointed guardian or with the biological parents who have
supposedly relinquished all parental rights, and they go to the
court registrars to see if the order was actually issued by the
court. An analysis of the order itself can show whether or not the
court followed its own procedures correctly.

20. In one particularly egregious case, a man came into the ACS
section and submitted 144 applications for Social Security Numbers,
along with 144 adoption orders, all supposedly completed by the same
magistrate on the same day. These 144 children were purported to be
the adoptive children of one man in the United States who had never
traveled to Nigeria and had never met any of these children. The
man who brought the applications was listed on the adoptions as the
lawyer for the American, though he admitted he was not in fact an
attorney. He also happened to be the biological father of three of
the children. Over the course of the interview, officers discovered
that the American was a World War II veteran, and that these
adoption orders were intended to allow these children to collect
education benefits from the Veterans Administration as the children
of a military veteran - at 588 dollars a month for each of the 144
children, it comes to over a million dollars per year.

21. The adoptions were clearly procedurally invalid, since the
'adoptive' father had never even met the children, so the Social
Security applications were denied. A visiting magistrate from the
region in which the adoptions were conducted expressed surprise that
the judge listed on the adoption order, whom she knew personally,
would attach his name to such a clearly fraudulent enterprise.

-----------
DNA TESTING
-----------
22. DNA testing has proven an invaluable tool in the deterrence of
fraud. There are many instances where the evidence of relationship
that would allow officers to make their decisions is unreliable,
destroyed, or simply not available. Family photography, aside from
the occasional posed studio portrait, did not become widespread
until the late 1970s and early 1980s, and birth certificates have no
security features to speak of and can be obtained easily. Officers
request DNA testing fairly frequently. The samples, in the form of
cotton swabs, are collected by an IV LES at the clinic where the
required visa medical examinations are conducted. This is a duty
that is rotated around the section. The Consulate sends the samples
to the laboratory, and the notarized results are returned directly
back to the Consulate via courier.

23. Applicants who know their relationship is not bona fide, in
general, do not follow through with the DNA testing. In one case, a
man came for a K-1 fiance visa. He listed two children on his
application, but said they lived with their mother - to whom he said
he was never married - and would remain in Nigeria. The officer
believed the fiance relationship and issued the K-1. Shortly
thereafter, he returned to the Consulate and stated that he wanted
his oldest child to accompany him after all. The officer was
suspicious and during a subsequent interview for the child requested
DNA, at which point the man said that he had changed his mind and
would travel alone. Fairly certain now that the man was attempting
alien smuggling, the officer stated that the man's visa - on which
he had not yet traveled - would be cancelled pending the outcome of
the DNA testing. Sure enough, the DNA results showed a 0%
probability of paternity, and the man was refused under 6E for alien
smuggling.

---------
DHS FRAUD
---------

24. We continue to receive about ten requests a week for
transportation letters from legal permanent residents who report
their green cards lost or stolen. Without DHS presence at post or
access to their database, we struggle to confirm LPR status and
whether the LPRs have a criminal record.

25. The FPU receives and processes investigation requests from
USCIS District Adjudicating Officers to verify documents submitted
for many different types of petitions in the United States.
Recently, FPU was asked to verify the claims of two men who applied
for asylum in the United States based on their membership in MASSOB,
the Movement for the Actualization of the Sovereign State of Biafra,
which they describe as a persecuted underground organization. In
support of this claim, they submitted their membership cards and
letters from their chapter secretary stating that they were members.
Investigation showed that MASSOB is not, in fact, a clandestine
organization, but rather a public organization with well-known
leaders, and the cards and letters were forgeries; they used an
incorrect logo.

26. In both the IV and NIV section we see frequent attempts at
alien smuggling, whether through a sham marriage or the addition of
an extra child. In some cases it is merely a member of the extended
family who simply does not have a legal claim to the immigration
benefit. However, in some cases, such as the DV clip-ons, there is
a financial motivation; someone has agreed to pay in order to have
that person added to an otherwise-legitimate application.

27. In some instances, the smuggling takes place because an
applicant or American citizen believes the proper channels are too
time-consuming. In one IR-3 adoption case, the adopted child had
actually been living in the United States for a number of years.
After a lengthy interview with the American petitioner, who brought
the child to the interview, the FPM pieced together the story. The
petitioner came to Nigeria for a child, whom she obtained from an
organization that was subsequently discovered to be selling babies
to prospective parents. Instead of obtaining a proper visa for the
child, she traveled to the Caribbean with the baby, endorsed on her
Nigerian passport. She and the child traveled first to St. Lucia,
then to Puerto Rico, and finally took a domestic flight from Puerto
Rico to Dallas-Fort Worth. The American petitioner apparently used
her connections at the airline where she works to get them to look
the other way and allow her into the country with an undocumented
child.

-----------------
DS INVESTIGATIONS
-----------------

28. The consular section in general and the FPU in particular work
closely with the ARSO/I recently assigned to Lagos. Cases are
referred to the ARSO/I from IV, NIV, and ACS units, with the
referral documented in the notes for the case. The ARSO/I has aided
us in pursuing marriage fraud rings stateside through his U.S.-based
DS contacts, and here in Lagos he has been pursuing the vendors of
the fraudulent documents presented in interviews. His close working
relationship with the Special Fraud Unit of the Nigerian police has
resulted in the arrest of a number of fraudulent applicants.
Through spot reports he keeps the consular section informed of the
outcomes of the referred cases. The ARSO/I usually takes referrals
directly from interviewing officers regarding instances of fraud
that occur on a daily basis, while complex investigations that FPU
has conducted are referred to the ARSO/I by the FPM. ARSO/I and the
FPM have a strong working relationship and often collaborate on
interviews, investigations and training. ARSO/I and FPM also
benefit from the strong support of the Consular Chief and the
Regional Security Officer.

----------------------
HOST COUNTRY DOCUMENTS
----------------------

29. Nigeria recently updated its passport design to include a
microchip like the one added to U.S. passports. It includes
holographic and UV-reactant features, and each visa page in the
booklet has the passport number punched into the outside edge. The
older design is still valid and still in circulation; it consists of
a biodata page encased in plastic, UV-reactant features, and the
passport number punched into the top edge of the inside pages.

30. Civil documents, by contrast, have essentially no security
features. Marriage certificates vary widely in appearance; while
they follow the same basic format, each local government authority
has its own design. Marriage certificates and birth certificates
are both filled out by hand in ball point pen, and are printed on
plain white paper. These documents are incredibly easy to forge.
In addition, controls and oversight in government offices are such
that for sufficient payment a person can obtain virtually any
government document from the source. With very few exceptions,
documents are taken with a grain of salt, and without verification
by FPU that there is a corresponding entry in the logbook of the
office that supposedly issued the certificate or court order, we
consider most documents to be of very little value.

---------------------------------
COOPERATION WITH HOST GOVERNMENT
---------------------------------

31. The FPU has enjoyed a strong relationship with the Nigerian
Police Department for many years, referring cases to them where
Nigerian laws have been broken. The Special Fraud Unit has aided in
the arrest of applicants who have presented fraudulent documents, as
well as tracking down the document vendors.

32. The FPU has also enjoyed years of support from local
governments, schools and marriage registries in our verifications of
documents but lately, FPU investigators have been harassed by
registrars to provide money for verifications, usually 2,000 Naira,
the equivalent of about 17 dollars. This is apparently a revenue
collecting scheme on the part of the local government authorities.
In some cases, the working relationship between the investigator and
the registrar, with whom they have dealt before, has meant the
registrar could be persuaded to waive the fee.

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